Issue 7 2019

CEO MONTHLY / ISSUE 7 2019 13 Senior Manager & Certification Regime – The ‘Catch All’ Regulation making. Regulators are not prescriptive of the systems and type of IT adopted, but they demand close scrutiny of their use. Regulations including SS3/18, IFRS 9 and IFRS 17 are all relevant to modelling, in turn bearing an impact on OpRes and ultimately SMCR. Shadow IT offers flexibility to users, but these models typically aren’t implemented, documented or tested against a company’s standard IT policies; and therefore, may contain errors that can lead to poor business decisions, breach of regulations, or inflict reputational harm. They also lack change management controls, affecting auditability. A comprehensive approach to IT management for SMCR compliance With technology being one of the key elements of operational resilience – for which the C-suite is held responsible – there is a business driver to take a comprehensive view of the enterprise and Shadow IT estates and their impact. At the same time they need to balance their compliance needs with the need for the flexibility and agility that the business, and end users value deeply. Risking non-compliance of regulations – any of which imply a breach of SMCR – can have personal implications for the C-suite. In March 2020, the FCA will make live The Directory, a public source of information on individuals in key roles as part of the SMCR to provide consumers transparency and support the FCA, law enforcement, professional bodies and other regulators in monitoring the market. SMCR is complex, and its relationship with other regulations means this complexity is constantly evolving. However, approached the right way, there is scope and opportunity to address these issues, and conceivably use them to drive better management insight and enhanced business performance. About the author Henry Umney is CEO of ClusterSeven. He joined the comp any in 2006 and for over 10 years was responsible for the commercial operations of ClusterSeven, overseeing globally all Sales and Client activity as well as Partner engagements. In July 2017, he was appointed CEO and is strongly positioned to take the business forward. He brings over 20 years’ experience and expertise from the financial service and technology sectors. Prior to ClusterSeven, he held the position of Sales Director in Microgen, London and various sales management positions in AFA Systems and ICAP, both in the UK and Asia.